Safeguarding Policy

1. Scope

TWI is both an employer and a provider of goods, facilities and services. As such TWI has a duty under the Children Act 1989 and section 175 of the Education act 2002 to ensure that young persons and vulnerable adults are able to study and work in a safe environment.

2. Objectives

To safeguard young persons and vulnerable adults who may be in need of protection and to enable TWI to meet its duties under the Children Act 1989 and section 175 of the Education Act 2002.

The policy aims to ensure that, whilst on a TWI site:

• All our young people and vulnerable adults feel safe and are protected from harm
• TWI staff and volunteers, visitors and young people/vulnerable adults are aware of their expected behaviours whilst on TWI’s site
• Young people and vulnerable adults know how to raise concerns
• TWI staff and volunteers recognise the indicators that suggest a young person/vulnerable adult is suffering or at risk of abuse, neglect or harm
• TWI staff and volunteers are able to give an appropriate response to any concerns raised

3. Introduction

This policy is designed to provide a secure framework for all staff working or volunteering at TWI, in safeguarding and promoting the welfare of those young people/vulnerable adults who attend our apprenticeship programme and is applicable to all other situations where young people/vulnerable adults may attend a TWI site. Within our policy, apprentices come under the general heading of young people/vulnerable adults. Safeguarding is not just about protecting young persons from deliberate harm, it includes managing a young person/vulnerable adult’s health and safety and protecting our young people/vulnerable adults from bullying, racist abuse, harassment and online abuse, and helping young people to avoid missing education. The witnessing of abuse may have a damaging effect on those who are party to it, as well as the person subjected to the actual abuse, and may have a significant impact on the health and emotional well-being of the individual.

Abuse can take place in any family, workplace, institution or community setting, by telephone or on the internet. The effects of abuse can be difficult to recognise as young people/vulnerable adults may behave differently or seem unhappy for many reasons, as they move through the stages of life or their family circumstances change. However, it is important that staff at TWI know the indicators of abuse and to be alert to the need to understand what action one should follow. Abuse, neglect and safeguarding issues are rarely standalone events that can be covered by one definition or label. Often multiple issues will overlap.

Where appropriate, this policy links to other relevant policies, and the local county council safeguarding requirements. Our safeguarding arrangements are reported on a yearly basis to the executive board and our safeguarding policy is reviewed annually, to keep it in line with local and national guidance/legislation.

We are able to arrange for our policy to be made available to young people/ vulnerable adults whose first language is not English on request.

4. Ethos

TWI aims to ensure that anyone who uses TWI’s facilities, including all young people/vulnerable adults, feel that they will be listened to and that appropriate action taken to address any concerns that they may raise. TWI intends that young persons or vulnerable adults at TWI will be able to talk freely to any member of staff if they are worried or concerned.

Everyone at TWI has clearly defined responsibilities for ensuring that TWI as a whole creates a safe environment within which every young person/vulnerable adult has the opportunity to achieve their educational outcomes.

All staff and regular visitors will, either through training or induction know how to recognise a disclosure from a young person or vulnerable adult and will know how to manage this. However, TWI cannot make promises not to disclose secrets.

5. Responsibilities and Expectations

The TWI Executive Board has a legal responsibility to ensure that TWI has the following:

• An effective safeguarding policy and procedures to manage safeguarding and respond to allegations, made available to staff, and monitoring for compliance with the latest legislation
• A Designated Safeguarding Officer who has responsibility for dealing with all safeguarding issues at TWI
• Appropriate vetting of TWI educational staff and volunteers, to ensure they are safe to work with young people/vulnerable adults
• Training to ensure educational staff and volunteers are competent in safeguarding

The Cambridgeshire Corporate Director for Children and Adults has identified dedicated staff to undertake the role of Local Authority Designated Officer (LADO). LADOs can be contacted using the LADO central telephone number: 0300 123 2044 for allegations against all staff and volunteers. Or for Cambridgeshire local support: Monday to Friday during office opening hours:

Telephone: 01223 727 968; 01223 727 969; 01223 727 967.

 For out of hours queries, the Emergency Duty Team can be contacted on 01733 234 724.

TWI’s Designated Safeguarding Officer (DSO) is responsible for ensuring that all safeguarding issues raised at TWI are effectively responded to, recorded and referred to the appropriate agency. They are also responsible for arranging safeguarding training for all staff and volunteers who regularly and frequently work with young people at TWI and that this training takes place at least every three years. The DSO will work with HR to ensure safeguarding training is provided within the three year timescale.

The DSO is required to complete a safeguarding self-review assessment annually which demonstrates that the safeguarding arrangements at TWI are being met. If the self-assessment highlights any areas for improvement, this will be detailed in an action plan which will be signed off and monitored by the named Executive Board Member for safeguarding on behalf of the TWI Executive Board, to ensure these improvements are implemented. The self-review assessment is to be shared annually with the Local Authority, who will have a quality assurance role in ensuring TWI is meeting its safeguarding requirements.

Each business unit where there may be young people/vulnerable adults will have a Designated Safeguarding Lead (DSL), to manage the safeguarding process in their business unit and respond to any concerns and allegations.

All adult staff or volunteers at TWI shall act immediately on any child protection (CP) concerns raised. If TWI staff are concerned that a young person may be at risk or is actually suffering abuse, they should report this to the DSO immediately. If a young person/vulnerable adult may be at immediate risk and the DSO is unavailable, you are required to contact children’s social care via Customer First using the number 0808 800 4005 or call 999.

The Executive Board Member for oversight of safeguarding at TWI is the Research Director.

The DSO is: Heather Wawryka Tel 01223 897326 email; heather.wawryka@twi.co.uk

The DSLs within the TWI business units are: Heather Claxton (NSIRC).

6. Recognising concerns – signs and indicators of abuse

Abuse is defined as a form of maltreatment of a young person/vulnerable adult. Somebody may abuse or neglect a young person by inflicting harm. A young person may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others (e.g. via the internet). They may be abused by an adult or adults or another young person or young persons.

The following indicators listed under the categories of abuse are not an exhaustive list.

Physical abuse; a form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a young person. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a young person.

Emotional abuse; the persistent emotional maltreatment of a young person/vulnerable adult such as to cause severe and adverse effects on the young person’s emotional development. It may involve conveying to a young person that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the young person opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on them. These may include interactions that are beyond a young person’s developmental capability as well as overprotection and limitation of exploration and learning, or preventing the young person participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyberbullying), causing the young person frequently to feel frightened or in danger, or the exploitation or corruption of others. Some level of emotional abuse is involved in all types of maltreatment of a young person, although it may occur alone.

Sexual abuse involves forcing or enticing a young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the young person is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities, such as involving a young person in looking at, or in the production of, sexual images, watching sexual activities, encouraging a young person to behave in sexually inappropriate ways, or grooming a young person in preparation for abuse (including via the internet). Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other young persons.

Neglect; the persistent failure to meet a young person’s basic physical and/or psychological needs, likely to result in the serious impairment of the young person’s health or development. Neglect may involve a parent or carer failing to (i) provide adequate food, clothing and shelter (including exclusion from home or abandonment); (ii) protect a young person from physical and emotional harm or danger; (iii) ensure adequate supervision (including the use of inadequate care-givers); or (iv) ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a young person’s basic emotional needs.

(Source: Keeping Children Safe in Education September 2016).

7. Procedures for TWI Staff and Volunteers

7.1 What to do if you are concerned

If you are concerned about a young person or vulnerable adult, inform the DSL immediately.

7.2 What to do if you are approached regarding an allegation

If a young person/vulnerable adult makes an allegation or disclosure of abuse against anyone it is important that you:

• Stay calm and listen carefully, so that you can recall what you have been told
• Reassure them that they have done the right thing in telling you
• Do not investigate or ask leading questions. (However, you may be asked to gather enough information to contribute to good decision-making and an assessment of risk)
• Let them know that you will need to tell someone else
• Do not promise to keep what they have told you a secret
• Inform the DSL as soon as possible
• Make a written, signed and dated record of the allegation. Do not include your opinion without stating it is your opinion. Provide the record to the DSL without delay

7.3 Managing Allegations

Allegations may be made against TWI staff or volunteers that are working with or may come into contact with young people/vulnerable adults at TWI. If an allegation is made, this should be brought to the immediate attention of the local DSL (see section 6), who is to report it to the DSO. In the case of the allegation being made against the DSL, this is to be brought to the immediate attention of the DSO. The DSO will report allegations to the Cambridgeshire LADO, providing details in order for appropriate action to be taken, e.g. a meeting with the LADO and the police or other appropriate multi-agency partners.

Dependent on the allegation being made, the DSO will:

• Refer to the LADO immediately and follow up in writing within 48 hours
• Consider safeguarding arrangements of the young person to ensure they are away from the alleged abuser
• Contact the parents or carers of the young person if advised to do so by the LADO
• Consider the rights of the staff member/volunteer for a fair and equal process of investigation
• Act on decision(s) made in any meeting with the LADO
• Ensure that the appropriate TWI disciplinary procedures are followed, including whether to suspend a member of staff/volunteer from work until the conclusion of any investigation
• Advise the Disclosure and Barring Service (DBS) where a member of staff/volunteer has been dismissed or removed or would have been, had they not resigned, due to safeguarding concerns. This is a legal duty and failure to report to the DBS where the criteria have been met, is a criminal offence

8. Safe Recruitment

It is a requirement for all agencies to ensure that all staff recruited to work with young people/vulnerable adults are fit to do so. When recruiting such staff, TWI will ensure that the recruitment panel includes someone with the required recruitment and selection training, to ensure that the recruits are appropriately qualified and have the relevant employment history, references and vetting checks, in compliance with the Key Safeguarding Employment Standards.

There may be occasions when some form of physical contact is inevitable, for example if first aid is required or if someone is in a location of danger to themselves or others. For such situations, TWI has a procedure for physical intervention and safe restraint. If TWI staff or volunteers are working with young people/vulnerable adults alone, wherever possible, they will be visible to other members of staff, eg meeting rooms should have windows or a doors with an unobscured, clear glass panel or be left open.

9. Training

All members of staff or volunteers required to work with young people/vulnerable adults will have regular access to safeguarding training. As part of the induction, TWI will issue safeguarding information and will update staff and volunteers as appropriate, eg via the modifications to the staff code of conduct, staff handbook, this policy and any related policies. The DSO and DSLs will undertake further safeguarding training at least every two years, to update their awareness and understanding, and to enable TWI to ensure its safeguarding arrangements are robust.

10. Records and Monitoring

• Staff and volunteers that come into regular contact with young people/vulnerable adults at TWI, will be recorded on the Single Central Record, kept and monitored by HR
• Any safeguarding information recorded will be kept securely. Copies of referrals, invitations to child protection conferences or multi-agency discussions and meetings, core groups and reports will also be stored securely
• Records of attendance will be kept by TWI. If a young person/vulnerable adult falls below an accepted level of attendance our DSO will be informed, to determine if safeguarding action is required

11. Child Protection Conferences/Multi-Agency Planning Meetings

A child protection conference will be convened if a referral has been made and it is found that the young person/vulnerable adult is at risk of harm or if the young person/vulnerable adult is already subject to a child protection plan. TWI staff may have contact with parents and we will work in an open and honest way with any parent whose child has been referred to Children’s Social Care services or whose child is subject to a child protection plan. Our responsibility is to promote the protection and welfare of all young people and our aim is to achieve this in partnership with the parents.

Educational staff may be required to attend child protection conferences or follow on meetings to represent TWI. TWI staff attending will be provided with relevant up to date information about the young person/vulnerable adult. All reports for child protection conferences will be prepared in advance using the required county report format. The information contained in the report will be shared with parents at least one day before the initial child protection conference and at least 48 hours before the review conference.

12. Current Safeguarding Issues

Current safeguarding themes include: child sexual exploitation, bullying including cyberbullying, domestic violence, drug abuse, fabricated or induced illness, faith abuse, female genital mutilation, forced marriage, gangs and youth violence, gender-based violence/violence against females, mental health, preventing radicalisation, hate, sexting, teenage relationship abuse, trafficking, young people/vulnerable adults missing from home or care, young people/vulnerable adults missing education.

13. Useful Contacts

For further advice in relation to this policy speak to the DSO.

Multi-agency Safeguarding Hub (MASH) Professional Helpline: 03456 061 499

Cambridgeshire Police Cybercrime Unit: 

https://www.cambs.police.uk/information-and-services/Online-safety/Online-safety.aspx

Cambridgeshire Local Safeguarding Children Board:  https://www.cambslscb.co.uk

Cambridgeshire County Council: https://www.cambridgeshire.gov.uk

14. Referencing

Keeping Children safe in Education 2016